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Partnership paid royalties to partners

SDS
Level 1

I have a partnership that pays out royalties to individuals.  Some of these individuals are the partners themselves.  Are these payments to partners guaranteed payments for services?  

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1 Comment 1
LG-CPA
Level 4

Rev Rul 81-178, "To be a royalty, a payment must relate to the use of a valuable right."  The payment of royalties, by that definition is not a payment for services, and so cannot meet the definition of a guaranteed payment for services.